Comments on revised draft tariff language

1. Please provide comments in the revised draft tariff language posted on the initiative webpage and upload as an attachment:

Revised Draft Tariff Language - EIM Resource Sufficiency Evaluation Enhancements: https://www.caiso.com/InitiativeDocuments/RevisedDraftTariffLanguage-EIMResourceSufficiencyEvaluationEnhancements.docx

Please see the attached draft tariff language with comments.

1. Please provide comments in the revised draft tariff language posted on the initiative webpage and upload as an attachment:

Revised Draft Tariff Language - EIM Resource Sufficiency Evaluation Enhancements: https://www.caiso.com/InitiativeDocuments/RevisedDraftTariffLanguage-EIMResourceSufficiencyEvaluationEnhancements.docx

Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to review and comment on the CAISO’s draft tariff language for EIM Resource Sufficiency Evaluation Enhancements.

This draft tariff language is based on the Revised Draft Final Proposal dated December 16, 2021; therefore, SRP requests additional information on the CAISO’s plans to address stakeholder comments on that proposal as detailed below.

29.34 (n)(3)(A) Reliability Status – Notification

SRP and the Joint EIM Entities commented on the Revised Draft Final Proposal opposing a requirement for EIM participants to sign an attestation obligating them to notify the CAISO should they perform emergency actions. The requirement of an attestation would place an unnecessary burden on operations personnel during stressful conditions. SRP prefers that any Balancing Authority that declares a NERC-defined Energy Emergency Alert 2 (or equivalent) or greater be automatically deemed resource insufficient.

Because the draft tariff language references “timelines and procedures set forth in the Business Practice Manual for the Energy Imbalance Market” that are not yet available for review, it is unclear what additional actions the EIM participants would be required to take when performing emergency actions and what burden that would place on operations personnel.

1. Please provide comments in the revised draft tariff language posted on the initiative webpage and upload as an attachment:

Revised Draft Tariff Language - EIM Resource Sufficiency Evaluation Enhancements: https://www.caiso.com/InitiativeDocuments/RevisedDraftTariffLanguage-EIMResourceSufficiencyEvaluationEnhancements.docx

Please see the attached comments on the proposed tariff revisions.